Higher Thresholds for Transfer Pricing and Local File Requirements
On 1st February 2024 the Tax Department has issued an
announcement that in anticipation of legislative amendments on
transfer pricing provisions they will apply higher thresholds for
Local File requirements, from the year 2022 onwards.
More specifically:
– The threshold for the category of financing transactions
increases from €750.000 to €5.000.000.
– The threshold for all other categories of transactions
(Goods, Services, Royalties and Other transactions) increases from
€750.000 to €1.000.000.
It must be noted that transactions below the above thresholds are subject to simplified transfer pricing provisions and safe harbour rules, where applicable, as per the Circular 6/2023.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
